Mobile Edition

Defensive Tax Return Disclosures (ACDTR17)

Date:Thursday, December 7, 2017
Time:2:00 PM - 4:00 PM
(Registration at 1:30 PM)
Facility:Webcast or Webinar, Online
CPE Credit:2.0 Technical Business
Instructor: David R. Jenkins
Course Level:Intermediate
Early Bird Price:$79.00 FICPA Members, $109.00 Non-Members


Defensive tax return disclosures are made on Forms 8275 or 8275R, depending on whether the declared position is consistent or inconsistent with extant treasury regulations. However, the reason for filing defensive tax return disclosures goes beyond avoiding penalties associated with intentional disregard for rules and regulations. Preempting IRS deficiency notice presumptive correctness is a dominating consideration. This webcast explains.


Lesson 1.


Lesson 2.

Forms 8725 and 8725R and Intentional Disregard of Rules and Regulation Penalties

Lesson 3.

Affirmative Equitable Defenses

Lesson 4

Preempting IRS Deficiency Notice Presumptive Correctness

Lesson 5



  • Recognize important differences in correctly filing Forms 8725 and 8725R

  • Recognize equitable tax doctrine application can correctly set aside black letter law targeted benefits  

  • Recognize why it is important to correctly rebut the IRS presumption of correctness when filing client tax returns  

  • Recognize properly prepared affidavits and incorporated exhibits amount to defensive tax return disclosures that correctly reduce IRS controversies to questions of law

    Major Topics:

  • Forms 8725 and 8725R  

  • Penalties associated with intentional disregard of rules and regulations  

  • Equitable Tax Doctrines  

  • IRS deficiency notice presumptive correctness  

  • Preparing defensive tax return disclosures

    Who Should Attend:
    *CPAs *Attorneys *Enrolled Agents *Enrolled Retirement Plan Agents *Self-directed Retirement Plan Fiduciaries, Custodians, and Administrators *Self-directed Retirement Plan Account Holders *Tax Return Preparers

    This webcast is an intermediate continuing education webcast. It is assumed the webcast participant has achieved basic understanding of the following: Equitable tax doctrines, Penalties associated with intentional disregard of rules and regulations, & Issues involving IRS deficiency notice presumptive correctness

    Advanced Preparation:


    If listed below, select the appropriate sessions or options to continue with your purchase.

    Registration Status: CLOSED - Online registration for this course is now closed. Please contact the Member Service Center at (800) 342-3197 if you wish to inquire about registering.